Investor Presentaiton

Measures to prevent re-occurance Start period 2016 Jun Mar 2016 Top Message (Intranet, internal newsletter) Categories Rule revision, strengthen organization Jul Internal training Jul-Sept Internal investigation 2017 May Rule revision, strengthen organization May Rule revision, strengthen organization Jul-Aug Internal training Aug-Oct Internal investigation 2018 Apr-Jun 2019 Jun Internal investigation Internal investigation Dec Internal investigation Measures taken Revision of Antimonopoly Act Compliance Guidelines Antitrust seminars Internal hearing on Antimonopoly Act compliance Create Antitrust Guideline for Meeting with Competitors Starting the operation of Antitrust Compliance System Group sessions for sales staff Internal leniency on Antimonopoly Act Regular audit for tender by Legal Dept. Regular audit for tender by Legal Dept. Widen the scope of regular audit and internal hearing by Legal Dept. Initiatives Expanding the scope of rotation system for managers, who are at (Rule revision, strengthen organization) scheduled in 2020 Frequency, target, content Enriched content on cartels and bid-rigging, and listed many specific cases Regularly held Lectured by outside counsel Hearing of each business unit and group companies Stricter regulation about get in contact with competitors Advance approval for transactions and meeting with competitors and control for bid participation information Regularly held Training for sales dept. employees by using case studies Conducted for each business unit and affiliated company Annually Audit on the deal specifics, justification for tender pricing, sales channel, etc. Annually Audit on the deal specifics, justification for tender pricing, sales channel, etc. Start preparation for audit to overseas group companies and for hearing to group companies in Japan same job for a certain period of time Revision of Antimonopoly Act Compliance Guidelines (Rule revision, strengthen organization) *Internal hearing by legal department for each business unit and group companies (Int. investigation) ⚫Ongoing seminars for executives by external legal counsel and sales department employees (Int. training) kuraray Internal leniency conducted by survey for sales department employees (Int. investigation) 30 50

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